Document mpeRrq3oO0v9Qgz1wMVEDzBkb

I - 0OO\Le is-asso FRANCIS E. MARSHALL GERALD A. OENNEHEY JOHN R. WARNER ROBERT J. COLEMAN ROBERT ST. LEGER GOGCIN JOHN P. RENDERS JOHN J. COFFEY EDWARD R. MURPHY* JOSIPH M. WALKER JOHN W. WALTER PAUL A. BECHTEL, JR. CHARLES W. CRAVEN ROBERT 0. HANNA, JR. THOMAS C DLORENZO DANIEL J. SHERRY JOHN S. TUCCI, JR. EOWARO R. TAYLOR PETER S. MILUR ANTHONY P. TINARI DANIEL J. RYAN, JR. FRANCIS E. MARSHALL, JR. ANNE M. KENNEY WILLIAM W. FEEIHOFER* RALPH A. MICHETTI WILLIAM S. WEINER PAUL R. BRADY III CHRISTOPHER K WRIGHT MICHAEL P.OEEDON ^Haxslratl, Ranter, Gloltnran mtLr (Soaqin COUNSELLORS AT LAW -- PROCTORS IN ADMIRALTY 1515 LOCUST STREET PHILADELPHIA, PENNSYLVANIA 19102 2I5-B93-3800 CABLE AOORESS MARSHALL RECEIVED 527 SWEDE STREET NORRISTOWN, PA. 19401 215*279-5433 22 W. SECOND STREET MEDIA, PA. 19043 215-LO-4-U48 May 13, 1980 MAY 10 1980 30 WASHINGTON AVBJUt ENTRY HADOONPIRLD, NJ. 0(033 409-944-1450 legal department ALSO MEMBER NEW JERSEY 8AI James K. Green, Esquire Johns-Manville Corporation Ken-Caryl Ranch Denver, Colorado 80217 Re: VanArsdale vs. Johns-Manville Corp., et al. Feb. Term, 1978, No. 516 (109) Case No. 21 ___________ ,, Dear Mr. Green: Please be advised that we finished up the second half of the deposition of Thomas VanArsdale. He is {59 years old, married and is the father of 4 children. He has 2 sons who live at home. One works 'Si a pipefitter at the Philadelphia Naval Shipyard and the other is a paraplegic, who apparently gets no financial assistance from any source other than Mr. VanArsdale. Mr. VanArsdale made a fair impression as a witness and seemed honest throughout his testimony. The only area that Mr. VanArsdale exaggerated was the amount of time that he sustained heavy exposure. Most of the time between 1946 and 1960, Mr. VanArsdale was employed as a mechanic at the Philadelphia Naval Shipyard. He stated that he spent 80 to 90% of his time in the shop. During the later part of that period, he was promoted to a shop planner. From 1963 to 1973, Mr. VanArsdale was a general foreman machinist. His product identification was basically weak. He stated the he worked with and around gaskets, blankets, sections, blocks and cement. He identified Johns-Manville. Owens-Coming. Pittsburgh Corning, Garlock and Eaglff-FIcher. He said that he might have seen a GAF product while working in the yard. Most of his information concerning product identification came from Joseph Gaus, a co-worker and a plaintiff in the Albert group of cases. We have scheduled his deposition for May 22, 1980 for the purpose of obtaining more product identification information. CRMC-M&S-002542 James K. Green, Esquire Page Two May 13, 1980 Mr. VanArsdale's medical history is an interesting one. In 1968, he received 2 badly broken ankles when he was assaulted in Long Beach, California while on a business trip for the navy. According to Mr. VanArsdale's testimony, a burglar jumped from a canopy on top of him while he was entering his hotel. His ankles continue to swell up to the present time and these injuries were listed as the major reason for his disability retirement in 1973 >m the Philadelphia Naval Shipyard. Mr. VanArsdale's own doctor, Iula and the navy yard doctors agreed that Mr. VanArsdale was mamentlsL^-i gab]ed from employment at the shipyard due to the .lowing reasons: 1. Bilateral fractures of the ankles; 2. (Pulmonary emphysema; and 3. Bronchitis. The plaintiff insistScthat he stopped smoking in the early sixties after having started in 1950 at the rate of 1 1/2 packs a day. Plaintiff's other medical problems are listed and explained more thoroughly in the enclosed medical reports of Dr. Rodman and Dr. Heiman. Unfortunately, we were unable to elicit any testimony which would give us any reason to believe that a statute of limitations issue was ripe. If you need any additional information, please do not hesitate to contact me. DJR/ar Enclosure cc: Kathleen Friedmann (w/enc.) CRMC-M&S-002543